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c C

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MAR 2 8 2000

,I'

MCI WORLDCOM INC 'u

DIRECT TESTIMONY OF ILENE HARDEN-ADKINS

BEFORE THE PUBLIC SERVICE COMMISSION

OF SOUTH CAROLINA

DOCKET NO. 1999-423-C

APRIL 11, 2000

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Q: Please state your name?

A: Ilene Harden-Adkins.

Q: With whom are you employed, and at what address?

A: MCI WorldCom. 2520 Northudnds Parkway, suite 400 Alpharetta, GA 30004

Q: What is your position with MCI WorldCom, and for how long have you held that

position?

A: I am the Senior Manager ofBrand Marketing for the Prepaid Division, and have

been in that position since July 1999.

Q: Please describe your responsibilities in that position?

A: I am responsible for developing and managing the prepaid product offerings,

including the placement ofproper disclosures on the card, packaging and point of sale

("POS") material.

Q: What is your professional and educational background?

A: I have a Masters Degree in Business Administration from Radford University.

My professional history includes developing and managing prepaid marketing issues over

the last five (5) years with ConQuest, SmarTalk, and ATILT, all of which are

telecommunications carriers..

Q: What is the purpose ofyour testimony here7

A: My purpose is to assist the South Carolin'a Public Service Commission

("Commission") in promulgating appropriate rules for prepaid calling service, and to

explain to the Commission MCI WorldCom's business relationship and experience with

that service.

Q: Is MCI WorldCom in the business of selling prepaid calling services7

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A: Yes. As such, MCI WorldCom through its certificated subsidiaries sells prepaid

calling cards on a national basis. Understandably, we prefer uniformity of regulation as it

affects our business, since uniformly keeps costs low and hence, the consumer pays a

lower price for our products. MCI WorldCom has implemented and used a set standard

of internal practices and procedures for the provisioning ofprepaid card services. We

standardize disclosures on prepaid cards, packaging and POS material because our

prepaid cards are distributed nationally. Since these practices and procedures are national

in scope, we would incur significant costs in systems development to modify existing

practices if each state adopted different rules.

Q: Is MCI WorldCom a member ofany trade associations that advocate a code of

conduct or industry guidelines, and which provide guidance to consumers and public

officials?

A: Yes. We are a member of the International TeleCard Association ("ITA") and are

actively involved in that organization. ITA is a trade association with a diverse

membership representing various aspects of the prepaid card industry, including for

interexchange carriers, resellers, card printers, promotional card companies, publishers,

and card collectors. The association focuses on consumer education regarding the

industry, as well as consumer protection. The association works within the industry to

establish industry standards an'd to represent the industry in state rulemaking proceedings.

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Q: Have you had an opportunity to review the Proposed Prepaid Calling Service

Regulations ("proposed Regulations") of the Commission, as well as the prefiled

testimony of James M. McDaniel in support of those proposed regulations?

A: Yes.

Q: Please describe your overall reaction to the proposed Regulations?

A: MCI WorldCom commends the Commission and Commission staff for undertaking

the challenge ofaddressing issues relating to prepaid calling cards. There is much in the

proposed Regulations with which MCI WorldCom agrees; for example, sections (1), (4) and

(5) (10) under "Standards for Prepaid Calling Services and Consumer Disclosure"

(sometimes referred to as the "Standards").

Q: What is your opinion with regard to the sections of the proposed Regulations

denoted "Definition" and "Certificate of Public Convenience and Necessity Required"?

A: We are largely satisfied with these sections, but I do have a couple ofquestions and

comments.

With regard to "carrier," so long as the intent is to apply that defiuition to

telecommunications carriers, i.e., carriers providing a prepaid telecommunications service,

for services that are subject to the Commission's jurisdiction, I have no problem with the

definition. Thus the definition should not apply, for example, to cellular or paging services,

or to selling at wholesale usage on a telecommunications network. MCI WorldCom does

not believe that the Commission has jurisdiction over interstate or international cards (and,

for the latter, there are variable rates for call termination to more countries (at least 180) than

can be described on cards and other materials. Most cards with international termination

include a package insert that lists applicable rates for the most frequently called countries).

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With regard to the certification requirement, so long as "prepaid calling service" is

already encompassed within the categories of local exchange service, interexchange service

or other services for which certificates have already been issued to carriers that are

providing prepaid calling services, I have no problem with the requirement. Of course, a

carrier that seeks to provide prepaid calling services but has not yet received certification

&om the Commission for local exchange service or interexchange service would have to

obtain an appropriate certificate ofpublic convenience and necessity.

Q: With regard to the section "Tariffs and Price Lists," do you have anyconcerns':

Yes. Although I agree with the requirement of filing a tariff or price list that

states the maximum amount a user will be charged per minute for usage, as well as the

amount(s) of applicable surcharges, as discussed below with regard to sections (2) and

(11) of the "Standards for Prepaid Calling Services and Consumer Disclosure" there are

several problems with expressing surcharges in an "equivalent per minute rate", whether

in a tariff or in disclosures to a consumer.

Q: What are the problems you foresee in attempting to express surcharges in an

"equivalent per minute rate"?

A: First, there are charges that, while not per-minute usage charges, are not quite

"surcharges"; for example, a "maintenance" or flat fee or per line charge, which may be

charged on a per month or other periodic basis. We certahtiy agree that all such fees and

surcharges and their costs and methods of application should be disclosed, but it would

be impracticable to characterize some of these charges on a per minute basis.

Second, it is not possible to express hypothetical charges in whole numbers for an

equivalent cost per minute for every card. For example, a card may offer $0.07 per

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minute, with a $0.25 connection charge, and a $ 1 per morith line (i.e., flat) maintenance

fee. Odd numbers do not translate well into equivalent per minute rates that are

understood by consumers.

Moreover, the type of call made with the card may dictate that a different

surcharge is applicable. For example, the same card may have different surcharges,

depending on whether a payphone is used.

Third, the proposed Regulations do not indicate what assumptions a carrier would

use in calculating such arate. There is no "standard" length ofacall. Consumers

themselve's have different assumptions about their intended use of a card, which renders

any particular assumption (i.e., the 'cost" of a ten minute call) that purports to apply to

every situation impracticable or irrelevant.

What I mean is that consumers buy different types of cards for different types of

anticipated situations. Some consumers prefer a card with a relatively high surcharge,

but relatively low per minute usage rates. Others prefer relatively low surcharges, with a

higher per minute usage rate. The difference in preference may depend on the number of

minutes of use or other conditions that are characteristics of or applicable to a particular

card. So consumers have different expectations about uses ofa card and hence a

particular assumption about the use of a card may be more confusing than helpfuL

Last, the proposed Regulation in this regard creates an opportunity for erroneous

reporting by carriers and consequently, exposure to enforcement actions by Attorneys

General and class action litigation for perceived errors and fraud.

The bottom line is that it is not practicable to express charges invariably in terms

of prices per minute. Surcharges and fees, however, should be fully disclosed in terms

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the consumer understands. Accordingly, we recommend that disclosure of the amount

and method of application of the surcharge be stated in per-minute terms, or in terms of

dollars and cents or in terms of "units". For example, if a card discloses that "1 unit"

equals I domestic minute of usage, and the per-doniestic minute usage charge is

disclosed, and the card also discloses that a payphone surcharge is "2 units," then the

consumer will understand what he or she will be charged for using a payphone to make

the call. Some carriers currently indicate the first minute "cost" (i.e., taking into account

the surcharge) of a call, plus the "cost" for each successive minute, to show how

surcharges or maintenance fees are calculated. So the consumer may be adequately

advised on the terms and conditions ofuse of the card, without attempting to express

surcharges or other fees in terms of an "equivalent per-minute" amount.

Q: Is there anything else in section (2) of the "Standards for Prepaid Calling Cards and

Consumer Disclosures" that may be ofconcern?

A: Yes. I am concerned about "insur[ing]" that consumer disclosures that MCI

WorldCom makes will be provided to the consumer. I also believe it impracticable to

provide consumer disclosures on the calling card and packaging and displays or

advertisements at the POS. This concern also relates to section (6) of the proposed

"Standards". Finally, I have some comments with regard to disclosing the expiration policy.

Before I discuss these issues, however, let me explain the transactions by which MCI

WorldCom cards typically are disseminated to consumers.

MCI WorldCom distributes prepaid calling cards to companies that then distribute

the cards to their stores or to their franchisees, which then distribute the cards to

consumers. The distributois receive a commission on the retail transactions. We also

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distribute cards to distributors, which may market the cards to sub-distributors, which

then market the cards through independent stores or to consumers. In either case, MCI

WorldCom enters into an agreement with the first entity that orders the cards from us. In

legal terms, we are in "privity of contract" with that entity and with no other party in the

chain of transactions that results, ultimately, in the sale to the consumer. Our agreements

require that our cards be distributed with certain packaging, as well as with POS

materials,. The packaging, as well as much of the POS materials (except, generally

speaking, where they are small), contain consumer disclosures of the type that the

proposed Regulations contemplate.

Q: Why is this explanation important?

A: This explanation is important for at least two (2) reasons, in the context of the

proposed Regulations.

First, although our agreements are enfdrceable as against the first entity in the

chain of transactions that result, finally, in the sale of the card to the consumer, the

agreements are enforceable ~oui as to that entity. Moreover, we cannot "insure" or

"ensure" that the disclosures we provide will be provided to a consumer.

Second, since packaging is sold with the card to the consumer, requiring certain

disclosures to be on cards and packaging is redundant, and, in fact, the packaging actually

may mask on-card disclosures. The maximum charge per minute is presently placed by

MCI WorldCom on packaging and POS materials, rather than on the cards themselves. The

packaging itself, since it has more space than a calling card, and is what the consumer reads

when purchasing cards, is intended as the primary disclosure vehicle. Moreover, the larger

POS materials (like posters) typically contain consumer disclosures, but it is impractical

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to require such disclosures on smaller POS, such as a door cling that may say "Prepaid

Cards sold here". POS material is not always used by retailers; nor is it always pracncal to

be used with respect to the retail sale of cards. Once in the retailer's location, POS material

is no longer within the canier's control. The carrier or someone else in the "chain" can

provide it, but retailers may not post this material, or even have a place to post it near the

actual POS. Moreover, even ifcarriers provide POS material, retailers may not keep that

material current. We cannot enforce disclosure obligations as against retailers, and thus

caiinot "insure", by way of contract, that customer disclosures are made.

Q: What does MCI WorldCom recominend with respect to the placement of

consumer disclosures?

A: MCI WorldCom considers our packaging to be the primary point-of-sale vehicle.

As the Commission is aware, most prepaid cards are about the same size as a credit card,

so that they may easily fit in a wallet. Available space is severely limited. Dialing

instructions, access numbers, personal identification numbers, retail bar codes, tracking

numbers, magnetic stripes, customer service access numbers, service and tariff

disclosures limit the remaining space available on the card for additional disclosures.

Thus we agree that the disclosures required by section (I) under the "Standards"

would be placed on the card itself.

We further recommend that disclosures be placed on packaging, when packaging

is the principal pre-sale disclosure vehicle. If cards and packaging, liowever, are not

visible to the consumer before the sale, such as when a vending machine is used to

dispense cards, then disclosures should be placed on POS material. Since MCI

WorldCom does not believe that POS material should be the primary pre-sale disclosure

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tool in a retail store, disclosures in that context should be placed on packaging, with

disclosures on POS material to be made optional unless, in a given instance, cards are to

be sold without packaging. If certain disclosures are to be required for the larger POS

material, we prefer that those disclosures be limited to a toll-fic customer service

number and/or web site for additional information.

To illustrate these points, at hearing I'l make available one or more examples of

cards, packaging and POS material.

Q: With regard to the expiration policy, do you have any comments'?

A: For the same reasons expressed above with regard to POS material, we would

prefer not to have expiration dates/policy required on POS material, if it is disclosed

elsewhere. Expiration dates will vary with the services and the activation method. If

expiration policy is disclosed on cards or packaging, it is redundant to include it on POS

material.

Q: Is MCI WorldCom satisfied with the proposed section (3), dealing with Customer

service, under the "Standards'* part of the proposed Regulation?

A: Generally, yes; however, customer service, which is nationally based, cannot be

expected to know the certificate number of the carrier. Consumers are not concerned

about this particular information, in any event.

Q: With regard to the requirement in section (7), that the billing increment not

exceed one minute, do you have any recommendation?

A: We recommend increments of one minute, unless otherwise disclosed. Thus the

section could be modified to read: " one minute unless a different rounding policy is fully

disclosed."

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Q: Concerning sections (8) and (9) under "Standards," do you have any

recommendations or questions?

A: First, I would need clarification as to what is meant by "conversation time"?

Does this time commence from the time the call is completed to the caller's destination

number?

Second, I believe that the phrase "and fees*'hould be added to the end of section

(8).

Last, we recommend a modification of se'ction (9), to read: "rounded up to a full

minute unless a different rounding policy is disclosed."

Q: With regard to the commencement date for application of the proposed

Regulations, do you have any recommendations?

A: Yes. Long lead times are required for card production, particularly given

extensive inventories in carrier and distributor warehouses. Contracts are already in

place that must not be affected by new rules. Carriers and distributors must have time to

work through existing inventory, print new cards, etc. Scrapping inventory ultimately

increases the costs for consumers. The Commission should consider modifying the

sentence to read "produced alter" a date certain, and cards produced prior to that time

should be "grandfathered" to minimize inventory destruction and allow carriers and

retailers to sell inventory. In terms of a date for the proposed Regulations to go into

effect, we need six (6) months to a year to fully implement disclosure requirements, and

to allow both carriers and distributors to work through existing inventory and print new

cards. Increases costs for consumer. A year is more realistic, because new disclosures

need to be phased in over time as new cards are ordered and produced.

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Closely related to this issue is the fact that our products are not state-specific.

Thus when a particular state adopts new regulations, nationally based inventories may

become obsolete. The cost of destroying and re-printing then constitutes a burden for

carriers and distributors. This cost is not recovered.

Q: What about the proposed Refund policy?

A: The phrase "unusable for reasons beyond the consumer's connol" needs to be

modified. Carriers can't be responsible for something that happens outside their control.

"Unusable," moreover, is very broad and subjective. For example, was the caller unable

to complete a call to India because India did not have the capacity to handle the caller or

a service was not available in a war zone?

The MCI WorldCom policy is "no refunds" once the card is activated. The

Commission should be mindful that the distributor collects a higher price from the

consumer than we collect from the distributor. Prepaid calling cards are like cash or

negotiable instruments, and should be treated as such. The retail price ofcards would

increase ifwe refund cash to a consumer.

We suggest adapting the following language from our FCC TariffNo. I, revised

Page No. 19.592, section 2665:

MCI WorldCom will provide a credit equal to oneminute of applicable service for MCI WorldCom prepaidcard calls that are interrupted or are subject to inadequatetransmission. Credits will not be issued when aninterruption or service deficiency is: 1) not reported to theCompany; or 2) due to failure of power, equipment orsystems not provided by MCI WorldCom.

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Q; Do you think a bonding requirement is necessary?

A: No. As Mr. McDaniel states, the Florida Public Service Commission did not

approve such a requirement. I do not believe it should apply here. With regard to my

company, MCI WorldCom is a large carrier, is already (through its subsidiaries)

certificated, and should not have to post a bond. If, in certificating new entrants that

propose to provide prepaid calling cards, the Commission thinks bonding is necessary, it

could be imposed at that time.

Q: Does this conclude your testimony"

A: Yes.

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CERTIFICATE OF SERVICE

I, Betty J. DeHart of Woodward, Cothran & Herndon, Attorneysfor MCI WorldCom Network- Services, Inc., and MCI WorldCom

Communications, Inc., do hereby certify that I have served a copy

of the Direct Testimony of Ilene Harden-Adkins by causing to be

deposited in a United States Postal Serv'ice mailbox copies of thesame, postage prepaid, addressed to the persons indicated below.

F. David Butler, EsquirePublic Service Commission.

of South CarolinaPost Office Drawer 11649Columbia, S. C. 29211

Dallas D. Ball, EsquirePost Office Box 419Ballentine, S.C. 29002

Bonnie D. Shealy, EsquireRobinson, McFadden & Moore, P.C.Post Office Box 944Columbia, S. C. 29202

Francis P. Mood, EsquireSinkler & Boyd, P.A.Post Office Box 11889Columbia, S.C. 29211

Caroline N. Watson, EsquireBellSouth TelecommunicationsPost Office Box 752Columbia, S. C. 29202

Elldott F. Elam, Jr., EsquireS. C. Department of Consumer AffairsPost Office Box 5757Columbia, S. C. 29250-5757

Margaret M. Fox, EsquireMcNair Law Firm, P.A.Post Office Box 11390Columbia, S.C. 29201

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Stan J. Bugner, State DirectorGTE Service Corporation, II1301 Gervais Street, Suite 825Columbia, S.C. 29201

SWORN to before me thisday of 4~W , 2000.

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Robert A. CulpepperAttorneyLegal Department

Suite 8211600 Hampton StreetColumbia. South Carotna 2920t803 253-5953Fax 803 254-1731

March 28, 2000 rxi'nsIOrt

The Honorable Gary E. NalshExecutive DirectorPublic Service Commission of SCPost Office Drawer 11649Columbia, South Carolina 29211

Re: Proceeding for the Review of Staff' Proposal forRegulations Applicable to Prepaid CallingServicesDocket No. 1999-423-C

Dear Mr. Walsh:

Enclosed please find for filing in the above-referencedmatter an original and twenty-five copies of the DirectTestimony of C. L. Addis.

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8. c. pUBL(cspRvlc

By copy of this letter, BellSouth is serving the same onall parties of record.

Robert A. Culpepper

RAC/nml

Enclosure

cc: All Parties of Record

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of23E COMMISSIOl4

BELLSOUTH TELECOMMUNICATIONS, IN

DIRECT TESTIMONY OF C. L. ADDIS

BEFORE THE SOUTH CAROLINA PUBLIC SERVICE COMMISSION

DOCKET NO. 1999-423-C

MARCH 28, 2000

Q.

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PLEASE STATE YOUR NAME, BUSINESS ADDRESS AND POSITION8. r. ni

WITH BELLSOUTH TELECOMMUNICATIONS, INC. (HEREIN R

REFERRED TO AS "BELLSOUTH").

MY NAME IS C. L. ADDIS AND I AM EMPLOYED BY BELLSOW~~BI.ECP(I-

MANAGER IN REGULATORY. MY BUSINESS ADDRESS IS 1600

HAMPTON STREET, COLUMBIA, SOUTH CAROLINA.

15 Q. PLEASE GIVE A BRIEF DESCRIPTION OF YOUR BACKGROUND AND

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EXPERIENCE.

18 A. I GRADUATED FROM THE UNIVERSITY OF GEORGIA WITH A DEGREE

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IN BUSINESS ADMINISTRATION. I STARTED WITH BELLSOUTH IN

1969, AND WORKED IN THE CUSTOMER SERVICE DEPARTMENT

PRIOR TO MY PRESENT ASSIGNMENT. MY CURRENT

RESPONSIBILITIES INCLUDE COORDINATING, SUPPORTING, AND

MANAGING TARIFF FILINGS WITH THE COMMISSION AND

PROVIDING ASSISTANCE REGARDING TARIFF INTERPRETATIONS

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1 AND IMPLEMENTATION, BOTH WITHIN AND OUTSIDE THE

2 COMPANY.

4 Q. WHAT IS THE PURPOSE OF YOUR TESTIMONY?

6 A. THE PURPOSE OF MY TESTIMONY IS TO COMMENT ON THE

COMMISSION STAFF PROPOSED PREPAID CALLING SERVICE

8 REGULATIONS (HEREINAFTER, "REGULATIONS"). THE PRIMARY

8 FOCUS OF MY TESTIMONY IS TO SEEK CLARIFICATION AND MAKE A

1'0 SUGGESTION WHICH BELLSOUTH BELIEVES COULD IMPROVE THE

11 REGULATIONS.

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13 Q. WHAT ITEMS OF THE REGULATIONS DO YOU THINK NEED

14 CLARIFICATION?

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16 A. THERE ARE THREE ITEMS WHICH IN MY OPINION NEED

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CLARIFICATION:

I) WHETHER THE REGULATIONS APPLY TO PREPAID CALLING

CARDS USED EXCLUSIVELY FOR WIRELESS COMMUMCATIONS?

2) WHETHRR THE BOND REQUIREMENT SHOULD APPPLY TO AN

INCUMBENT LOCAL EXCHANGE CARRIER ("ILEC") SUCH AS

BELLSOUTH?

3) WHETHER THE REGULATIONS REQUIRE THE CERTIFICATED

NAME OR "DOING BUSINESS AS" NAME BE THE MOST

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PROMINENT NAME AND/OR THAT THE NAME APPEAR ON THE

FRONT OF THE CARD?

4 Q. DOES BELLSOUTH HAVE ANY SUGGESTED CLARIFICATIONS?

6 A. YES. BELLSOUTH IS OF THE OPINION THAT THE REGULATIONS

SHOULD BE CLARIFIED AS FOLLOWS

I) CLARIFY THAT THE REGULATIONS DO NOT APPLY TO PREPAID

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CALLING CARDS USED EXCLUSIVELY FOR WIRELESS

COMMUNICATIONS. THIS CLARIFICATION WOULD BE

CONSISTENT WITH COMMISSION ORDER NO. 94-630, DATED JUNE

29, 1994, ISSUED IN DOCKET NO. 94-356-C, WHEREIN THE

COMMISSION DETERMINED THAT IT WOULD NOT EXERCISE ANY

REGULATORY AUTHORITY OVER COMMERCIAL MOBILE RADIO

SERVICES ("CMRS").

2) EXEMPT FROM THE REGULATION'S BOND REQUIREMENT ANY

ILEC THAT THE COMMISSION IS CURRENTLY REGULATING.

3) CLARIFY THE CERTIFICATED NAME AND/OR "DOING BUSINESS

NAME"'OES NOT HAVE TO BE SHOWN ON THE FRONT OF THE

CARD BUT MUST BE LEGIBLY SHOWN SOMEWHERE ON THE

CARD.

23 Q. WHAT SUGGESTION DOES BELLSOUTH HAVE WHICH COULD

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IMPROVE THE REGULATIONS?

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1 A

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THE REGULATIONS CONTAIN A SECTION ENTITLED "STANDARDS

FOR PREPAID CALLING SERVICES AND CONSUMER DISCLOSURE."

ITEM (2) OF THIS SECTION SETS FORTH THE INFORMATION

REGARDING CHARGES WHICH MUST BE PRINTED ON A CALLING

CARD AND OTHER MATERIALS VISISIBLE AT THE POINT OF SALE OF

A PREPAID CALLLING CARD. REQUIRING SUCH INFORMATION TO

BE DISPLAYED ON THE CARD ITSELF IN ADDITION TO MATERIALS

VISIBLE AT THE POINT OF SALE MAY BE A REQUIREMENT THAT IS

OF LITTLE OR NO BENEFIT TO A CONSUMER. SPECIFICALLY, SUCH

A REQUIREMENT DOES NOT APPEAR TO FURTHER THE

COMMISSION'S GOAL OF ENABLING A CONSUMER TO MAKE AN

INFORMED DECISION PRIOR TO THE PURCHASE OF A PREPAID

CALLING CARD. ADDITIONALLY, TO COMPLY WITH THE

REQUIREMENTS OF SUBSECTIONS (A) AND (B) OF ITEM (2), A

CARRIER MUST ASSUME AN UNDEFINED CALL LENGTH. IF

CARRIERS CHOOSE DIFFERENT CALL LENGTHS TO COMPUTE THE

PER MINUTE CALCULATIONS REQUIRED BY SUBSECTIONS (A) AND

(B), THE RESULTING PER MINUTE CHARGES HAVE THE POTENTIAL

TO BE CONFUSING AND MISLEADING TO THE CONSUMER. AS AN

EXAMPLE, THE IMPACT ON A PER MINUTE BASIS OF A SURCHARGE

ASSESSED ON A TWENTY MINUTE CALL IS FAR LESS THAN IF THE

SAME SURCHARGE IS CALUCLATED BASED ON A THREE MINUTE

CALL. THERERFORE, BELLOUTH RECOMMENDS THAT ITEM ( 2) AND

SUBSECTIONS (A) AND (B) OF ITEM (2) BE REVISED AS FOLLOWS:

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EACH CARRIER SHALL PROVIDE THE FOLLOWING INFORMATION

LEGIBLY PRINTED ON THE PREPAID CALLING CARD, PACKAGING,

DISPLAY, PROMOTION/ADVERTISING MATERIAL VISIBLE IN A

PROMINENT AREA AT THE POINT OF SALE OF THE PREPAID

CALLING CARD, AND/OR THE CARD ITSELF SUCH THAT THE

CONSUMER CAN~ INFORMED DECISIONS PRIOR TO PURCHASE:

A. MAXIMUM CHARGE PER MINUTE, EXCLUDING SURCHAGES IF

ANY, FOR USE OF THE PREPAID CALLING CARD SERVICE

B. ACTUAL DOLLAR AMOUNT OF ANY APPLICABLE SURCHARGES

10

11 Q PLEASE SUMMARIZE YOUR TESTIMONY.

13 A. BELLSOUTH APPLAUDS THE COMMISSION FOR DRAFTING THE

14

15

16

17

PROPOSED REGULATIONS WHICH ARE DESIGNED TO PROTECT

BOTH THE CONSUMER AND THE INDUSTRY. BELLSOUTH IS OF THE

OPINION THAT ITS SUGGESTION AND CLARIFACTIONS WILL

IMPROVE THE REGULATIONS.

18

18 Q

20

21 A

22

23

DOES THIS COMPLETE YOUR TESTIMONY?

YES.

25

ACCEPTED

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OCESSIN

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UBUC SERVICE CO'W

STATE OF SOUTH CAROLINA

COUNTY OF RICHLAND

)

) CERTIFI)

The undersigned, Nyla M. Laney, hereby certifiesthat she is employed by the Legal Department for BellSouth

Telecommunications, Inc. ("BellSouth") and that she has

,caused the Direct Testimony of- C. L. Addis filed on behalf

of BellSouIh Telecommunications, Inc. in Docket No. 1999-

423-C to be served "by placing 'such in the care and custody

of the United States Postal Service with first-class postage

affixed thereto and addressed to the following this March

'28', '20(Ã

Florence P. Belser, EsquireStaff AttorneyS. C. Public Service CommissionPost Office Box 11649Columbia, South Carolina 29211(PSC)

Francis P. Mood, EsquireSinkler a Boyd, P.A.The Palmetto Center1426 Main Street, Suite 1200Columbia, South Carolina 29201-2834(ATET Communications of the SouthernStates, Inc.)

M. John Bowen, Jr., EsquireMargaret M. Fox, EsquireMcNair Law Firm, P.A.Post Office Box 11390Columbia, South Carolina 29211(SCTC)

ACCEPTED

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Stan J. BugnerState DirectorNations Bank Tower1301 Ger~is StreetSuite 82SColumbia, South Carolina 29201(GTEECC)